opha-beyond-coal

Beyond Coal:
Ontario Public Health Association
November 2002
Power, Public Health
and the Environment

Beyond Coal:
Ontario Public Health Association
November 2002
and the Environment
Kim Perrotta, BES, MHSc.
OPHA Air Quality Coordinator

Table of Contents
Beyond Coal:
and the Environment
ii
Reference:
Ontario Public Health Association (OPHA). Beyond Coal: Power, Public Health
and the Environment. Toronto, Ontario: 2002.
Author:
Kim Perrotta, OPHA Air Quality Coordinator
Project Advisory Committee:
This project benefited greatly by the expertise, policy direction and editorial
advice offered by the Project Advisory Committee that included:
Paul Callanan, Manager, Environmental Health, Peel Health Department
Helen Doyle, Manager, Environmental Health, York Region Health Services De-
partment
April Eby, Health Promotion Officer, Environmental Health and Lifestyle Resource
Division, Waterloo Region Community Health Department
Beckie Jas, Environmental Health Specialist, Health Protection Services - Health
Department, Halton Region
Ronald Macfarlane, Supervisor, Environmental Health Assessment and Policy,
Toronto Public Health
James Moore, Air Quality Energy Manager, Environmental Health and Chronic
Disease Prevention, Middlesex-London Health Unit
Dr. Monir Taha, Associate Medical Officer of Health, Social and Public Health
Services, City of Hamilton
Acknowledgements:
While the views and positions articulated in this report are those of the author,
the Project Advisory Committee, and the OPHA, the OPHA would like to thank
those individuals who work in governmental agencies such as Environment
Canada and Health Canada, non-governmental organizations such as Pollution
Probe, the Ontario Clean Air Alliance, and the Canadian Energy Efficiency Asso-
ciation, and companies such as Toronto Hydro Energy Services Inc. and Torrie
Smith Associates, for providing information and/or comments that were benefi-
cial to this report’s development.
Appreciation:
The OPHA would also like to express its appreciation to the Walter and Duncan
Gordon Foundation for funding the OPHA Air Quality Program in 2002/2003.

Table of Contents
Ontario Public
Health Association
Distribution:
Copies of this report are available on the OPHA website www.opha.on.ca. Hard
copies can be requested from the OPHA at info@opha.on.ca or 416-367-3313.
For more information, contact:
Kim Perrotta, OPHA Air Quality Coordinator at kim.perrotta@cogeco.ca or
Helen Doyle, Lead for Air Issues, OPHA Environmental Health Work Group,
at helen.doyle@region.york.on.ca or 905-830-4444 ext.3101.
ISBN # 0-929129-54-7
Printed on recycled, chlorine-free paper
iii

Table of Contents
Beyond Coal:
and the Environment
Table of Contents
Executive Summary
Concerns Related To Ontario’s Electrical Sector
Actions Needed
Recommendations
I Why Is This The Time To Talk About Coal?
II Why Move Beyond Coal?
1. Four Concerns With Coal-Fired Power Plants
2. Coal Plants Contribute To Climate Change
3. Coal Contributes To Smog Formation
4. Coal Plants Produce Acid Rain
5. Coal Is A Major Source Of Mercury
III What Needs To Be Done?
1. A Three-pronged Approach Required
2. Energy Efficiency Has To Be Encouraged
3. Renewable Energies Have To Be Encouraged
4. Coal-Fired Power Plants Should Be Phased Out
IV How Do We Get There?
1. Action Needed From The Federal Government
2. Action Needed From The Province
3. Action Needed From Municipalities
Endnotes
Glossary Of Terms And Abbreviations
References
1
1
3
3
8
10
10
12
19
23
24
27
27
27
29
33
37
37
38
43
46
47
49
iv

Executive
Summary
1
Ontario Public
Health Association
Executive Summary
Concerns Related To Ontario’s Electrical Sector
This report has been prepared by the Ontario Public Health Association
(OPHA), a non-profit organization that represents the staff and professionals
who work in public health units and community health centres throughout
Ontario. It focuses on Ontario’s electrical sector, its impact on air quality,
human health and the environment, because this sector is currently undergo-
ing huge changes. In May of this year, Ontario’s electrical market was opened
to competition, a change that presents both risks and opportunities.
With a visionary regulatory framework, a competitive electrical sector could
actually encourage the development of alternative energy sources, co-genera-
tion, and energy efficiency measures that would be beneficial to air quality,
human health and the environment. However, without the proper regulatory
framework, competition could lead to increased use of electricity and greater
reliance on coal-fired power plants, which could result in further degradation
of air quality and the environment, and greater harm to human health.
The increased use of coal-fired power plants is a concern because they are
significant contributors of the air emissions that lead to: 1) global climate
change, 2) smog, 3) acid rain and 4) mercury contamination of the aquatic
food chain.
Global Climate Change
Scientists worldwide have documented a shift in the global climate over the
last century that is unprecedented for its pace of change. Most believe that
this change is due, in most part, to human activities. Of particular concern is
the release of carbon dioxide (CO2
) that results from the burning of fossil fuels
such as gasoline, oil, coal and natural gas. Consequently, global climate
change is inextricably linked to the energy policies of nations around the
world, as well as to their economic growth and population size.
Global climate change could have profound impacts on the health of whole
populations in regions spanning the globe. The direct health impacts expected
include those associated with increases in heat waves, air pollution, and
extreme weather events such hurricanes and floods. The indirect health
impacts expected include those associated with increases in drought, loss of
water supplies, shifts in food supplies, and changes in the range of insect-
borne and infectious diseases.

Executive
Summary
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Beyond Coal:
and the Environment
The Intergovernmental Panel on Climate Change (IPCC) has concluded that
greenhouse gas emissions will have to be reduced to a small fraction of their
current levels in order to stabilize atmospheric concentrations of CO2
and
retard global climate change. Under the Kyoto Protocol, Canada is committed
to reducing greenhouse gas emissions to 6% below 1990 levels between 2008
and 2012. While this reduction represents a small percentage of the reduc-
tions that will ultimately be needed, ratification and implementation of the
Kyoto Protocol is an essential first step in the international process required to
properly address global climate change.
In Ontario, coal-fired power plants were responsible for 20% of greenhouse
gas emissions in 2001, while in the United States, they were responsible for
33% of total greenhouse gas emissions.
Smog
Ontario’s coal-fired power plants were responsible for about 23% of the sul-
phur dioxide (SO2
) and 14% of the nitrogen oxides (NOx) emitted in the
province in 2001. Both air pollutants can harm human health when present in
their gaseous form (e.g. as sulphur dioxide and nitrogen dioxide) and when
converted to acid aerosols such as sulphates and nitrates that make up a
significant percentage of the fine particulate matter in Ontario’s air. NOx are
also precursors for ground-level ozone, the air pollutant that triggers most of
the smog alerts in Ontario.
The Ontario Medical Association (OMA) has estimated that the fine particulate
matter in Ontario’s air contributes to approximately 1,900 premature deaths
each year, while researchers at Health Canada have demonstrated that the
gaseous air pollutants such as nitrogen dioxide and ozone, are responsible for,
on average, 7.7% of premature deaths each year in cities such as Toronto,
Hamilton, London, Ottawa and Windsor.
Acid Rain
While huge improvements have been made on air emissions of SO2
in both
Canada and the United States since the 1970s, acid rain remains a serious
environmental problem today. In 1997, a multi-stakeholder task group struck
by the federal government concluded that SO2
caps in Ontario, Quebec, and
the mid-western and eastern States, would have to be reduced by an addi-
tional 75%, if most of eastern Canada were to be protected from acid rain.
The task group has also called for reductions in NOx because of their contri-
bution to acid rain.

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Ontario Public
Health Association
As indicated above, Ontario’s coal-fired power plants were responsible for
about 23% of the SO2
and 14% of the NOx emitted in the province in 2001,
while the electrical sector in the United States was responsible for about 70%
of the SO2
and 25% of the NOx emitted in that country.
Mercury Contamination Of The Aquatic Food Chain
Mercury is a highly toxic element that is capable of accumulating in the
aquatic food chain. In recent years, negative health impacts have been docu-
mented among children whose mothers ate fish during pregnancy. The Na-
tional Academy of Science (NAS) has estimated that over 60,000 children per
year in the United States are born at risk from adverse neuro-developmental
effects due to prenatal exposure to mercury.
In 1994, under the Canada-Ontario Agreement Respecting the Great Lakes
Basin Ecosystem, mercury was targeted for a 90% reduction by the year 2000.
While other sectors in Ontario have made significant progress towards this
goal, Ontario’s electrical sector has increased emissions of mercury. In 1999,
coal-fired plants were responsible for about 23% of mercury emissions from
human activities in the province.
Actions Needed
In order to ensure that a competitive electrical sector produces results that are
beneficial to human health and the environment, regulations and policies
must be developed that: 1) Encourage energy efficiency; 2) Promote renewable
technologies; and 3) Phase-out the use of coal-fired power plants.
Encouraging Energy Efficiency
Ontario’s Select Committee on Alternative Fuel Sources has concluded that
energy efficiency measures are actually more important to meeting Ontario’s
future energy needs than are new energy supplies. In the 1990s, electricity
demand in Ontario was reduced by 25,000 Gigawatt-hours (GWh) annually
from the figure expected through increases in energy efficiency. This repre-
sents almost 17% of the total electricity generated for Ontario in 2001. The
energy experts, Torrie Smith Associates, have estimated that electricity de-
mand in Ontario could be reduced by up to an additional 35,000 GWh annu-
ally by 2012 with systematic efforts to increase energy efficiency in this prov-
ince. In addition, they have estimated that another 10,000 GWh per year of
electricity could be generated by industrial and commercial “co-generators”.
These estimates indicate that energy efficiency and co-generation combined,
could displace about 30% of all the electricity generated in Ontario in 2001,

Executive
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Beyond Coal:
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which is more electricity than was generated with coal-fired power plants in
2001 (i.e. 37,185 GWh).
The Commission for Environmental Cooperation (CEC), established under the
North American Free Trade Agreement, has identified changes in building
codes as the area with the greatest potential for energy efficiency in Canada
and the United States. In 1999, the residential, commercial and institutional
sectors in Canada were responsible for nearly 30% of secondary energy use
and 28% of greenhouse gas emissions in the country. Changes in Ontario’s
Building Code are recommended to encourage energy efficiency, renewables
and co-generation in new building stock, while a “shared savings mechanism”
that rewards electrical utilities that effectively encourage reductions in energy
consumption among their consumers, is recommended to increase energy
efficiency in existing buildings.
Promoting Renewable Technologies
The CEC, Ontario’s Select Committee on Alternative Fuel Sources, and the
Federal Liberal Caucus Working Group on Environmental Technologies have
all concluded that renewable energies have huge potential, from both techno-
logical and economic perspectives, to provide a significant share of clean and
secure energy in North America. Torrie Smith Associates have estimated that
new and renewable electricity, generated with wind, small hydro, and biogas,
has the potential to provide 20,000 GWh of electricity per year in Ontario;
5,000 GWh of which could be developed by 2012.
Many believe that the introduction of renewable technologies has been ham-
pered by government policies that are biased towards existing, conventional
technologies. For example, the Federal Liberal Caucus Working Group on
Environmental Technologies reported that, between 1970 and 1999, direct
federal spending on fossil fuel based energy was $40.4 billion, while federal
support for Canada’s nuclear industry exceeded $16.6 billion over the last five
decades. In countries that have revamped their public policies to support the
development of renewable energies, the results have been impressive. For
example, Germany, which began to invest in wind power in 1990, has devel-
oped 8,000 MW of wind-generated electrical capacity, and is also on track to
meet its target of 22,000 MW of wind-powered electrical capacity by 2010.
Germany’s 2010 target is only 2,700 MW less electrical capacity than Ontario
Power Generation currently has with its nuclear, hydro, coal-fired and oil-fired
facilities combined (i.e. 24,700 MW).

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Ontario Public
Health Association
The OPHA is recommending that the Ontario government establish a schedule
of ambitious Renewable Portfolio Standards (RPS) to promote the develop-
ment of renewable energies within Ontario, and that the Federal government
provide financial support to renewable technologies that is equal to that pro-
vided to conventional energy sources.
Phasing Out Coal-Fired Power Plants
Ontario’s Select Committee on Alternative Fuel Sources has recommended that
Ontario eliminate its reliance on oil- and coal-fired power plants by 2015.
Many organizations support the phase-out of coal-fired power plants because,
while they are one of the most significant sources of greenhouse gases, there
is currently no commercially available control technology that can be used to
reduce their CO2
emissions.
In Ontario, the greenhouse gases emitted from Ontario’s five coal-fired power
plants each year (i.e. about 35,000 kilotonnes in 2001) represent about 78% of
the greenhouse gas emissions that Ontario would need to cut in order to
achieve the 6% reduction envisioned by the Kyoto Protocol. A phase-out of
coal-fired power plants, driven by the need to reduce greenhouse gases, would
simultaneously produce a number of other public health and environmental
benefits. It would reduce SO2
emissions in Ontario by 23%, mercury emis-
sions by 23%, and NOx emissions by up to 14%.
Recommendations:
At The Federal Level
The OPHA recommends that the Federal government:
3 Ratify and implement the Kyoto Protocol as currently written, recogniz-
ing that it is only the first step towards the 60 to 80% reduction in
greenhouse gases that will be required to retard global climate change;
3 Provide municipalities with stable funding, that is not dependent upon
participation by the province, with which to promote energy efficiency
projects within their communities;
3 Establish a schedule of ambitious and increasing renewable energy
targets to guide the development of energy policies, environmental
regulations, and budgetary commitments at the federal level for the
coming years;

Executive
Summary
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Beyond Coal:
and the Environment
3 Provide financial support to renewable technologies that is equal to
that traditionally provided to conventional energy sources; and
3 Establish regulations under the Canadian Environmental Protection Act
(CEPA) that encourage the phase-out of coal-fired power plants by
2010.
At The Provincial Level
The OPHA believes that the Ontario government should move quickly on the
recommendations of Ontario’s Select Committee for Alternative Fuel Sources,
and recommends that the Ontario government:
3 Instruct the Ontario Energy Board (OEB) to establish a shared savings
mechanism that rewards utilities for investing in energy efficiency
programs that effectively reduce electricity consumption and their
customers’ bills;
3 Move immediately to revise the Ontario Building Code to incorporate
the most advanced science with respect to renewable energies, co-
generation, and energy efficiency;
3 Establish a schedule of increasing Renewable Portfolio Standards (RPS)
that meets or exceeds the most ambitious program established in North
America; and
3 Ensure that the emission trading scheme developed for Ontario:
4 Is a cap and trade model consistent with that proven effective in
the United States;
4 Significantly improves air quality and protects public health across
the regional air shed on both sides of the border;
4 Is supported by air emission caps for the electrical sector that will
result in the phase-out of coal-fired power plants by 2010;
4 Includes a hard cap of 25 kilotonnes (kt) for nitrogen oxide emis-
sions from fossil-fuelled power plants in southern and central
Ontario to be achieved by 2007; and
4 Limits imports and exports of electricity to generators that achieve
emission performance rates for mercury, nitrogen oxides, sulphur
dioxide, and carbon dioxide that are as good as, or better than,
those achieved by high efficiency natural gas generators.

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Ontario Public
Health Association
At The Municipal Level
The OPHA recommends that municipalities:
3 Establish ambitious energy efficiency programs that include specific
targets and timelines for their corporate operations and ensure that
financial savings are re-invested in energy efficiency projects and/or
used to support purchasing policies that favour renewable energies and
low emission generators of electricity;
3 Develop and implement corporate purchasing policies that favour
renewable energies and low-emission generators of electricity;
3 Establish programs to encourage large organizations within their com-
munities to establish ambitious energy efficiency programs;
3 Encourage large organizations within their communities to adopt
purchasing policies that favour renewable energies and low emission
generators of electricity; and
3 Establish social marketing programs to encourage energy conservation
efforts among individuals in their communities.

Why is this the time
to talk about coal?
8
Beyond Coal:
and the Environment
I Why Is This The Time To
Talk About Coal?
Restructuring In The Electrical Sector
In Ontario, there are four major sectors that contribute to air pollution, acid
rain and global climate change — the transportation sector, the electrical
sector, the residential/commercial sector, and the industrial sector. This report
focuses on Ontario’s electrical sector because this sector is currently undergo-
ing huge changes.
In May 2002, Ontario’s electricity market was opened to competition. For
many decades, electricity in Ontario had been generated and distributed by
Ontario Hydro, a crown corporation owned by the provincial government and
run by an arm’s length Board of Directors. Other companies
were not allowed to generate electricity for consumers in Ontario.
This began to change in October 1998, when the Ontario govern-
ment proclaimed Bill 35, the Energy Competition Act.
Under Bill 35, new companies have the opportunity to generate
electricity for consumers in Ontario. The intent of the Bill, ac-
cording to the Ontario government, is to provide cost savings to
customers by providing a competitive market in electricity pro-
duction.
Bill 35 also set the stage for the dismantling of Ontario Hydro into five new
organizations:
y Ontario Power Generation (OPG) which generates electricity in competi-
tion with other companies;
y Hydro One which has responsibility for running the electricity transmis-
sion system;
y The Independent Electricity Market Operator (IMO) which manages the
competitive electrical market on a not-for-profit basis;
y The Electrical Safety Authority (ESA) which has responsibility for setting
safety standards for the industry; and
y The Ontario Electricity Financial Corporation (OEFC), a crown corporation
that has responsibility for paying off the stranded debt of Ontario Hydro
(OMOEE, 2002).
OntarioCleanAirAlliance

Why is this the time
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Ontario Public
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Competition Presents Risks And Opportunities
The introduction of competition presents both risks and opportunities. With a
supportive regulatory framework, a competitive electrical sector could actually
encourage the development of alternative energy sources, co-generation and
energy efficiency that would be beneficial to air quality, the environment and
human health. However, without a proper regulatory framework, competition
could increase reliance on coal-fired power plants and result in further degra-
dation of air quality and the environment, and increased harm to human
health.
Competition Can Increase Pollution
In the United States, the introduction of competition to the electrical sector
resulted in increased production from some of the “dirtiest” coal-fired power
plants. A report prepared by the Northeast States for Coordinated Air Use
Management (NESCAUM) indicated that several large electric power compa-
nies in the mid-western United States substantially increased their wholesale
electricity sales between 1995 and 1996; that the increases in power were
provided by the highest polluting coal-fired power plants belonging to each
company; and that these increases resulted in substantial increases in emis-
sions of NOx and other air pollutants (NRDC, 1998).
This trend is not surprising because the “dirtiest” coal-fired plants in the
United States are the oldest plants that have not been required to upgrade
emission controls. Consequently, these plants have the lowest capital costs
and can produce electricity at very competitive rates.
Competition Can Discourage Energy Conservation
In a competitive electrical market, utilities tend not to offer energy efficiency
programs unless there is a regulatory structure that provides financial benefits
for doing so. In jurisdictions that have introduced competition to their electri-
cal sectors, investments in energy efficiency have declined following market
restructuring (CAEE, 2001). Most of these jurisdictions have since introduced
funding mechanisms or energy efficiency centres to compensate for this ten-
dency (CAEE, 2001). To date, these regulatory supports have not been pro-
vided in Ontario (Lourie, 2002).
Before the introduction of competition to Ontario, Ontario Hydro developed
energy efficiency programs to reduce the expenses associated with building
new electrical capacity. Since the introduction of competition, Ontario Hy-
dro’s successor company has withdrawn resources from energy efficiency
programs in order to reduce costs (CAEE, 2001).

Why move
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Beyond Coal:
and the Environment
II Why Move Beyond Coal?
1. Four Concerns With Coal-Fired Power Plants
The primary concern with the introduction of competition to Ontario’s electri-
cal sector is that it could lead to greater reliance on coal-fired power plants.
Coal is one of the oldest and dirtiest fuels used to generate electricity. There
are four major reasons to be concerned about coal-fired power plants. They
are among the most significant sources of air pollutants that contribute to:
1) Global climate change
2) Smog
3) Acid rain and
4) Mercury contamination in the aquatic food chain.
Coal-Fired Power Plants In Ontario
In the last few years, coal-fired power plants in Ontario have been used to
produce almost one third of the electricity generated in Ontario, and were
responsible for approximately:
y 23% of the sulphur dioxide (SO2) emissions in this province in 2001;
y 14% of the nitrogen oxide (NOx) emissions; and
y 20% of Ontario’s greenhouse gas emissions; and
y 23% of the mercury emissions in 1999 (OPG, 2002a;OMOE, 2001a)(see
Table 1).
The Nanticoke Generating Station, located near Simcoe on Lake Erie, is one of
the largest coal-fired power plant in North America. In 2001, it was responsi-
ble for about one half of the air emissions released from the five coal-fired
power plants operating in Ontario (OPG, 2002a).
Coal-fired power plants also emit a large variety of other air pollutants includ-
ing chromium, nickel, arsenic, dioxins, hexachlorobenzene, hydrochloric acid,
hydrogen fluoride, cobalt and radon gas (OPG, 2001; TPH, 2002; USGS, 1997).
Some of these pollutants are carcinogens, some are persistent in the environ-
ment and capable of accumulating in the food chain, and all are toxic to plant,
animal and/or human life.
10
Beyond Coal:
and the Environment

Why move
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Ontario Public
Health Association
Ontario Power Generation (OPG)
Ontario Power Generation (OPG) is the successor company to Ontario Hydro
responsible for generating electricity in Ontario. In 2001, OPG generated 85%
of the total electricity used in Ontario. It generated approximately 127,200
Gigawatt-hours (GWh) of electricity: 40% with nuclear-powered generators,
33% with fossil-powered generators, 26% with water-powered generators, and
less than 1% with new renewable energy sources (OPG, 2002).
Its fossil fleet includes five coal-fired power plants and one plant that can be
fired with oil or natural gas (see Table 2 below). OPG has announced its
intention to sell three of its five coal-fired power plants — Lakeview, Thunder
Bay and Atikokan. In 2001, the Ontario government passed a Regulation
requiring that the Lakeview Generating Station be converted away from coal if
it continues to operate as a generating station after April 31, 2005 (OMOE,
2001a).
(Data from OPG, 2002)
*Nitrogen oxides are reported as nitric oxide (NO)
** Mercury is reported for 1999 (OMOE, 2001a)
Table 1: Emissions from Ontario’s Five Coal-Fired Power Plants, 2001
Plant Sulphur
Dioxide
(tonnes)
Nitrogen
Oxides
(tonnes)*1
Mercury
(kg) **
Carbon
Dioxide
(tonnes)
86,500
28,300
19,000
8,810
4,480
147,090
22,400
11,800
5,050
1,970
950
42,170
246.6
135.0
83.2
67.1
63.0
629.9
20,260,000
9,420,000
2,760,000
1,880,000
850,000
35,170,000
Nanticoke
Lambton
Lakeview
Thunder Bay
Atikokan
Total
(Data from OPG, 2002)
Table 2: Electricity Generation from OPG Fossil-Fired Power Plants, 2001
Plant Original
In-Service
Date
Electricity
Generated
(GWh)
Capacity
(MW)
FuelLocation
Nanticoke
Lambton
Lakeview
Lennox
Thunder Bay
Atikokan
Total
Lake Erie
Near Sarnia
Mississauga
Kingston
Lake Superior
W. of Lake Superior
Coal
Coal
Coal
Oil/Gas
Coal
Coal
3,920
1,974
1,138
2,140
310
215
9,700
21,124
10,472
3,081
3,243
1,670
838
40,428
1973-78
1969-70
1962-69
1976-77
1981-82
1985

Why move
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Beyond Coal:
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1860 1880 1900 1920 1940 1960 1980 2000
Year
0
0.2
0.4
0.6
0.8
-0.2
-0.4
-0.6
Degrees C
Coal-Fired Power Plants In The United States
In the United States (U.S.), where coal is used to generate about one half of
that country’s electricity, the electrical sector was responsible for approxi-
mately:
y 70% of the SO2
released in 1998;
y 25% of the NOx;
y 35% of the carbon dioxide (CO2
); and
y 25% of the air emissions of mercury (CEC, 2002).
Many of the U.S. coal-fired power plants are located in the mid-western states
that are upwind from Ontario due to prevailing wind patterns. As a result,
these coal-fired power plants are significant contributors of the air pollution
that affects human health and the environment across Ontario.
2. Coal Plants Contribute To Climate Change
Climate Change Has Already Begun
Global climate change is the most pressing environmental health issue of our
day. It has been projected that global climate change will increase the tem-
perature of air and water around the world, melt gla-
ciers, increase sea levels, increase the number and
intensity of extreme weather events that result in heat
waves, droughts, flooding and soil erosion (IPCC,
2001a). These changes have already begun. The Inter-
governmental Panel on Climate Change (IPCC) has
concluded that:
The northern
hemisphere has
warmed more in
the 20th century
than it has in the
past 1000 years.
Figure 1: Global Temperature Change, 1860-2001
(Environment Canada, 2001d)
Relative to 1961-90 average temperature
y Global mean air temperatures have increased by 0.4
to 0.8o
C over the 20th
century;
y Ocean temperatures have increased by 0.05o
C since
the 1950s;
y Summer sea ice over the Arctic has shrunk by 10 to
15% over the 20th
century; and
y Warming of the northern hemisphere during the 20th
century is likely to
have been the largest in any century in the past 1000 years (IPCC, 2001a;
NRC U.S., 2001).

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Ontario Public
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260
280
300
320
340
360
380
900 1000 1100 1200 1300 1400 1500 1600 1700 1800 1900 2000
Year
CO2conc.(ppmv)
Environmental Impacts Expected In Canada
In Canada, global climate change is expected to:
y Move the treeline significantly northward during this century;
y Increase the number and severity of forest fires;
y Affect the abundance of fish species by changing water temperatures and
circulation patterns;
y Melt permafrost in the far north;
y Decrease water levels in the Great Lakes by more than a metre and move
the shoreline of Lake St. Clair and Lake Erie up to six kilometres offshore;
y Increase droughts in the prairies; and
y Increase the frequency and intensity of heat waves (Canada, 2002).
It is the rate and magnitude of these changes that are the cause for concern.
Scientists worry that biological organisms, ecosystems, and human societies
will not be able to adapt to the changes because of the speed at which they
are occurring.
IPCC Attributes Climate Change To Human Influences
While there are a vocal minority who continue to question whether the hu-
man link to global climate change has been adequately proven, the majority of
experts in this field agree that the global climate is changing at an unprec-
edented pace, and that those changes are, in large part,
directly related to human activities. The IPCC jointly
established by the United Nations Environment Pro-
gramme and the World Meteorological Organisation,
concluded in its third assessment report that:
“Most of the observed warming over the last 50 years
is likely to have been due to the increase in green-
house gas concentrations;” and
“Emissions of carbon dioxide due to fossil fuel burn-
ing are virtually certain to be the dominant influence
on the trends in atmospheric CO2
concentrations during the 21st
century”
(IPCC, 2001b).
(Environment Canada, 2001d)
Figure 2: CO2
Concentrations Trends
Data from ice cores
Directly measured

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Beyond Coal:
and the Environment
U.S. NRC Concurs With IPCC
When the U.S. National Research Council (NRC U.S.) examined the science on
climate change in response to a request from the White House, it concluded
that:
“Greenhouse gases are accumulating in Earth’s atmosphere as a result of
human activities, causing surface air temperatures and subsurface ocean
temperatures to rise;”
“The changes observed over the last several decades are likely mostly due
to human activities, but we cannot rule out that some significant part are
also a reflection of natural variability;” and
“The IPCC’s conclusion that most of the observed warming of the last 50
years is likely to have been due to the increase in greenhouse gas concen-
trations accurately reflects the thinking of the scientific community on the
issue” (NRC U.S., 2001).
Climate Change Will Have Negative Impacts On Health
Global climate change could have profound impacts on the health of whole
populations in regions spanning the globe. The direct health impacts expected
include those associated with increases in heat waves, air pollution, and
extreme weather events such as floods, landslides, and hurricanes. The indi-
rect health impacts expected include those associated with: increases in
drought; changes in food and water supplies; changes in the range of insect-
borne diseases, water-borne diseases, and infectious diseases; and population
displacement and economic disruption (McMichael, 1996; IPCC 2001c).
More Heat Waves Expected
Global climate change is expected to result in a significant number of heat-
related deaths in both developed and developing countries as heat waves
become more frequent and more severe (IPCC, 2001). Analyses from around
the world indicate that overall death rates rise during heat waves, particularly
when temperatures rise above those to which the population has adapted
(Smoyer, 1999; McGeehin, 2001). For example, during a five-day heat wave in
1995 in which maximum temperatures ranged from 34 to 40o
C, the number of
deaths in Chicago, Illinois, increased by 85% while the number of hospital
admissions increased by 11% (McGeehin, 2001).
During the 1995
heat wave in
Chicago, there
were 700 more
deaths than were
expected for this
population during
this period of time
(McGeehin, 2001).

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beyond coal?
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Ontario Public
Health Association
A study conducted by Kalkstein and Smoyer indicated that several large cities
in Canada (i.e. those that currently experience hot, humid air masses during
the summer season such as Montreal, Toronto and Ottawa) could be very
negatively impacted by the increased temperatures expected with climate
change. For example, it was estimated that, with a doubling of CO2
in the
earth’s atmosphere, heat-related death rates could increase to between 9.63
and 33.65 per 100,000 in the Toronto area (Kalkstein and Smoyer, 1993). With
these rates, a city with Toronto’s current population, could experience be-
tween 239 and 835 premature deaths each year from heat alone (Chiotti et al,
2002).
The most common cause of death during heat waves is heatstroke where the
body temperature exceeds 105o
F. However, other causes of death include
strokes, heart attacks, respiratory diseases, accidents, homicide and suicide
(McGeehin, 2001). Young children and the elderly are particularly vulnerable
to heat waves because their bodies do not have the ability to regulate their
body temperatures under extreme conditions.
Those living in urban areas are also at greater risk during heat waves because
urban areas retain heat throughout the night more than rural and suburban
areas. A Missouri study found that the deaths from all causes increased by 57
and 64% respectively in two major urban centres during a 1980 heat wave,
while they rose by only 10% in the rural areas (McGeehin, 2001). The poor
can also be at greater risk because of substandard housing conditions, medical
conditions that increase vulnerability to heat, or because they lack access to
air conditioners, pools or cool recreational areas (McGeehin, 2001; IPCC,
2001).
More Air Pollution Expected
Climate change is expected to increase morbidity and mortality by decreasing
air quality in areas currently experiencing air pollution problems (IPCC,
2001c). Increased temperatures are expected to increase the average and
peak levels of ground-level ozone in the air by both, enhancing the chemical
reactions that give rise to ozone, and by increasing the release of volatile
organic compounds from natural sources (IPCC, 2001; Bernard, 2001; Mills,
1999). In urban environments, high humidity and low wind speeds are ex-
pected to increase the concentration of air pollutants such as fine particulate
matter that will stay in the air longer in high humidity (Bernard, 2001). In-
creased temperatures could also encourage greater use of electricity for air
conditioning, which could in turn result in a greater release of pollutants into
the atmosphere.
Central Canada
could experience a
5-fold increase in
smog episodes
and heat waves.

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Beyond Coal:
and the Environment
Kalkstein and Smoyer have predicted that, with a doubling of CO2
concentra-
tion in the atmosphere, central Canada could experience a five-fold increase in
offensive air masses that bring smog episodes, high temperatures and high
humidity. This means that smog episodes could increase in frequency from
4.7% of summer days to 23.3% of summer days in Ontario (Chiotti et al.,
2002). This increase in smog episodes is expected to significantly increase the
number of air pollution-related mortality and morbidity rates.
More Extreme Weather Events Predicted
Global climate change is expected to significantly increase deaths, disease and
injury by increasing the frequency and magnitude of extreme weather events
such as tornados, hurricanes, snowstorms, floods and cyclones. Extreme
weather events can be costly to human health. Between 1972 and 1996, on
average, about 123,000 people a year were killed by natural disasters around
the world (IPCC, 2001). The morbidity for natural disasters rises substantially
when one includes the indirect health effects such as respiratory infections
from living in crowded shelters, gastrointestinal infections that can occur
when water and sewage systems are disrupted, and trauma-induced mental
disorders (Greenough, 2001). Populations in developing countries are much
more affected by extreme weather events because they do not have the social
infrastructures needed to mitigate their impacts or to respond to them when
they occur (IPCC, 2001).
Extreme weather events are also costly in economic terms. For example, the
floods and drought associated with the El Nino event in 1982-83 led to losses
of about 10% of the gross national product (GNP) and about 50% of the
annual public revenue in countries such as Bolivia, Chile, Ecuador and Peru
(IPCC, 2001). The costs of extreme weather events have increased rapidly in
recent decades in both developed and developing countries. The yearly eco-
nomic losses from large events have increased 10 fold from $4 billion in U.S.
funds in the 1950s to $40 billion in U.S. funds in the 1990s. While these cost
increases are influenced by socio-economic factors such as population growth
and urbanization in vulnerable areas, they are also linked to observed changes
in flooding, precipitation and drought events (IPCC, 2001).
Insect-Borne Diseases Could Spread
Climate change is expected to affect the range, intensity and seasonality of
many diseases. There are concerns, for example, that insect-borne diseases
such as malaria, dengue fever, lyme disease could spread in range and inten-
sity with climate change (McMichael 1996; IPCC, 2001). While insect-borne
diseases will likely have a disproportionate effect on populations in tropical
climates, populations in northern climates will not be immune.
Yearly economic
losses from extreme
weather events have
increased from $4
billion (U.S funds) in
the 1950s to $40
billion in the 1990s.

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17
Ontario Public
Health Association
Environment Canada projects that insect-borne diseases such as malaria,
dengue fever, yellow fever and viral encephalitis could move into Ontario as
temperatures and humidity increase (Mortsch and Mills, 1996). West Nile
virus is an example of an insect-borne disease that, once introduced to New
York in 1999, has extended its range northward and westward due, in part, to
the milder winters and longer summers being experienced in North America
(TPH, 2001).
While the range of insect-borne diseases are highly dependent upon climatic
conditions such as temperature, rainfall and humidity, they are also dependent
upon living conditions (eg. access to air conditioning and window screens),
building materials, and social infrastructure. In wealthy nations such as
Canada, it is expected that the impacts of these diseases can be minimized
with a public investment in disease surveillance, education, habitat reduction
and mosquito control (Gubler, 2001; TPH, 2001).
Food Supplies Could Be Threatened
Global climate change is expected to alter regional temperatures, rainfall and
soil moisture, all of which could impair the growth of many crops in many
regions of the world (IPCC, 2001). In Canada, climate change is expected to
have a net negative effect on agriculture because, while temperatures will be
higher, the growing season will also be dryer (Env Can, 1997). Agricultural
output could also be affected by extreme weather events and altered patterns
of plant diseases and infestations.
Climate change is also expected to change water temperatures in oceans,
which could influence ocean currents and nutrient upwelling. These changes
could alter the distribution, migration and productivity of fish species upon
which humans are dependent for food supplies (McMichael,1996; IPCC, 2001).
One analysis predicts that an extra 40 to 300 million people could be at risk of
hunger by the year 2060 because of the impact of climate change. This
number is in addition to the 640 million who are expected to be at risk in the
absence of climate change (McMichael, 1996).
Social Justice Issue
There are also social justice aspects to the climate change issue. While there
are great uncertainties related to the extent and severity of the predicted
health impacts, there is a growing consensus that many of the anticipated
adverse effects will be greater in poorer regions of the world that lack food
supplies and/or well developed public health infrastructures with which to
An extra 40 to 300
million people could
be at risk of hunger
by the year 2060
because of the impact
of climate change.

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Beyond Coal:
and the Environment
respond to the changes (IPCC, 2001; NRC U.S., 2001). On the other hand, it is
clearly understood that those living in the wealthiest nations, particularly
those who live in North America, are the greatest emitters of the greenhouse
gases that are contributing to this shift in climate.
Canada, with 0.5% of the world’s population, is responsible for an estimated
2% of the net global greenhouse gas emissions (Canada, 2002). Canada is the
ninth largest emitter nation in the world and among the highest emitters per
capita (Canada, 2002). On average, each Canadian citizen is responsible for
greenhouse gas emissions that are almost 8 times higher than the global
average (CIELAP, 1996). While to some extent, this pattern of energy use
reflects the size of the county and its climate; it also reflects the inefficient use
of energy in a country that has developed in an era of cheap and abundant
energy.
Huge Reductions Required
In 1996, the IPCC indicated that greenhouse gas emissions would need to be
reduced by 50% of 1990 levels in order to stabilize concentrations in the
atmosphere and retard global climate change. In the third assessment report
published in 2001, the IPCC concluded that greenhouse gas emissions may
need to be reduced to a small fraction of current levels in order to stabilize
atmospheric concentrations of CO2
and retard global climate change (IPCC,
2001b). This suggests that greenhouse gas emissions may need to be reduced
by 60 to 80% within a number of decades if climate change is to be retarded
(Dauncy, 2001; David Suzuki Foundation, 1998).
Under the Kyoto Protocol, Canada is committed to cutting its greenhouse gas
emissions by 6% below 1990 levels between 2008 and 2012. While this reduc-
tion represents a small percentage of the cuts believed necessary to retard
climate change, some Canadian political leaders continue to argue against
ratification of the Kyoto Protocol, citing unacceptable economic costs.
Cost Estimates Of Kyoto And Climate Change
Estimates of the costs associated with the implementation of the Kyoto Proto-
col for Canada vary depending upon the assumptions applied in those analy-
ses. The Analysis and Modeling Group (AMG), a federal-provincial-territorial
working group created as part of the National Climate Change Process
(NCCP), estimated in 2000 that the Kyoto Protocol would reduce the GDP in
2010 by between 0 and 3% (Canada, 2002). Assessments conducted by a
number of academic economists and independent consultants since then,
have estimated that, with a global emissions trading framework in place, the
Greenhouse gas
emissions may
need to be cut by
60 to 80% in order
to retard climate
change.

Why move
beyond coal?
19
Ontario Public
Health Association
implementation of Kyoto would have a minor impact on the Canadian
economy. Their estimates range from –0.7% to +0.2% on Canada’s GDP in
2010 (Env Can, 2002a).
It is important to note however, that while these estimates may take into
account Kyoto’s costs to industry and consumers and Kyoto’s benefits in terms
of increased energy efficiency, they tend not to calculate the positive economic
opportunities that could be created by the Kyoto Protocol including those
associated with the development of renewable energy technologies (Env Can,
2002a). It is also true that most economic analyses fail to account for the
costs associated with the disruption of the natural ecosystem, and the human
health impacts that will result from that disruption (David Suzuki Foundation,
2002a).
Coal Plant Emissions: 78% Of Ontario’s Share Of Kyoto
Total greenhouse gas emissions in Canada are currently 700,000 kilotonnes per
year, up from 606,000 kilotonnes in 1990 (Torrie Smith Associates, 2002).
Ontario is responsible for about one quarter of Canada’s emissions and coal-
fired power plants are responsible for one fifth of Ontario’s emissions (OPG,
2002a). The greenhouse gases emitted from Ontario’s five coal-fired power
plants (i.e. about 35,000 kilotonnes each year) represent about 78% of the
greenhouse gas emissions that Ontario would need to cut (i.e. about 45,000
kilotonnes per year) in order to achieve the 6% reduction envisioned by the
Kyoto Protocol (data from OPG, 2002 & OMOE, 2002a). This suggests that
Ontario could go a long way towards meeting its Kyoto commitment if it
phased out coal-fired power plants.
3. Coal Contributes To Smog Formation
Coal-fired power plants are significant contributors of five of the air pollutants
most clearly linked to smog — ground-level ozone, fine particulate matter,
sulphates, nitrogen dioxide and sulphur dioxide.
Smog Increase Premature Deaths And Hospitalizations
Hundreds of studies, conducted in countries around the world, have demon-
strated that poor air quality can have a profound impact on human health.
Numerous studies have demonstrated that short-term spikes in air pollution
result in short-term increases in the number of deaths and hospital admissions
for lung and heart diseases (NAAQO, 1999a/b). One study has demonstrated
that deaths from strokes also increase consistently with rising concentrations
of the common air pollutants (Hong, 2002). Others have established that
Ontario could go a
long way towards
meeting its Kyoto
commitment if
it phased out coal-
fired power plants.

Why move
beyond coal?
20
Beyond Coal:
and the Environment
temporary increases in air pollution can reduce lung function, aggravate
asthma, and increase the number of respiratory infections in the population
(NAAQO, 1999a/b). These health effects have been demonstrated at air pollu-
tion levels that are common in Ontario today.
Smog Increases Chronic Heart And Lung Disease
While the majority of air quality studies have been directed at short-term
health effects, more recent studies of long-term health impacts suggest that air
pollution may also contribute to the development of chronic heart and lung
diseases including lung cancer. For example, a team of researchers that fol-
lowed 1.2 million adults in the United States over a 16-year period, found a
strong and consistent link between air levels of fine particulate matter (PM2.5
),
sulphates and sulphur dioxide (SO2
), and deaths from lung cancer, cardio-
pulmonary illnesses, and all causes. They concluded that air pollution in some
U.S. cities presents a health risk comparable to that presented by long-term
exposure to second hand smoke (Pope, 2002).
Children And The Elderly At Greatest Risk
While a mounting body of evidence suggests that air pollution can affect all
members of society, children, the elderly and those with predisposing respira-
tory conditions (such as asthma) or heart conditions (such as congestive heart
failure) appear to be most vulnerable (OMA, 1998; Burnett et al., 2001).
Ozone Irritates The Lungs
Ground-level ozone is the air pollutant responsible for most of the smog alerts
declared in Ontario. It is a secondary air pollutant formed in the air by a
reaction between NOx and volatile organic compounds (VOCs) in the presence
of sunlight. Because sunlight is needed for the reaction, air levels of ozone
are also related to the weather, and are higher in the summer months in
Canada.
Ozone has been linked to reduced lung capacity in healthy adults and chil-
dren, an increased rate of respiratory infections such as bronchitis and pneu-
monia particularly among young children, increased hospitalizations for lung
disease, and increased rates of non-traumatic deaths (TPH, 2000; OMA, 1998).
While it has long been understood that ozone can aggravate asthma symp-
toms, it is only recently that studies have suggested that ozone may actually
contribute to the development of the disease. For example, a ten year study
conducted by the University of Southern California has found that children
who live in high ozone communities and play three or more sports develop
asthma at a rate three times higher than those in low ozone communities
(CARB, 2002).
Childwithinhaler:PatMcGrath,OttawaCitizen
In some U.S. cities,
air pollution presents
a health risk
comparable to that
presented by long-
term exposure to
second hand smoke.

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beyond coal?
21
Ontario Public
Health Association
Figure 4: Annual Average & 90th Percentile,
Inhalable Particulate Matter, Ontario, 2000
Ozone Levels Frequently Excessive
Clear and consistent increases in non-traumatic deaths and hospital admis-
sions for respiratory illnesses have been documented at 1-hour ozone levels as
low as 20 parts per billion (ppb) and 25 ppb respectively (NAAQO, 1999a). As
illustrated in Figure 3, these air levels are exceeded on a regular basis in most
communities in Ontario (data from OMOEE, 2001).
Levels Of Fine Particulate Matter Frequently Excessive
Fine particulate matter (PM10/2.5
) is the name given
to the tiny airborne particles that are small enough
to be inhaled into the lungs. These particles, which
can include acid aerosols, metal fumes, organic
chemicals, pollen and smoke, are divided into
categories according to their size. Inhalable particu-
late matter (called PM10
) is less than 10 microns in
diameter while respirable particulate matter (called
PM2.5
) is less than 2.5 microns in size and enters the
lungs more deeply than PM10
.
Estimates suggest that sulphates, the acid aerosol
that is formed in the air from SO2
, represent about
25% of the PM10
and 40% of the PM2.5
in Ontario’s
air. Coal-fired power plants are one of the most
significant sources of SO2
in the province (about
23% in 2001)(OPG, 2002).
0
10
20
30
40
50
60
70
80
Windsor
Sarnia
London
Hamilton
St.Catharines
Oakville
Mississauge
TorontoW
FortFrances
ThunderBay
SaultSte.Marie
Sudbury
CopperCliff
PM10(ug/m3)
Annual Mean 90th Percentile
Figure 3: Annual Average & 90th Percentile, Ozone Levels, Ontario, 2000
0
10
20
30
40
50
60
Windsor
Sarnia
London
Simcoe
Kitchener
Hamilton
NiagaraRegion
Oakville
Mississauga
Toronto-West
York
Oshawa
Haliburton
Peterborough
Ottawa
Kingston
FortFrances
ThunderBay
SaultSte.Marie
NorthBay
Sudbury
Ozone(ppm)

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Beyond Coal:
and the Environment
Clear and consistent increases in non-traumatic
deaths and hospital admissions have been docu-
mented at daily PM10
and PM2.5
levels as low as
25 and 15 micrograms per cubic meter (ug/m3
)
respectively (NAAQO, 1999b). As figures 4 and 5
illustrate, these air levels are exceeded on a fairly
frequent basis in many communities in Ontario
(data from OMOEE, 2001).
The Ontario Medical Association (OMA) has
estimated that fine particulate matter in Ontario’s
air contributes to approximately 1,900 premature
deaths in Ontario each year (OMA, 2000).
Gaseous Air Pollutants Harm Health As Well
Several studies conducted on different continents in recent years have sug-
gested that the gaseous air pollutants also have a significant direct impact on
human health (Pengelly et al., 2000). For example, a 1998 study demon-
strated that nitrogen dioxide (NO2
), sulphur dioxide (SO2
), carbon monoxide
(CO) and ozone were responsible for 4.1%, 1.4%, 0.9% and 1.8% respec-
tively of all premature deaths in eleven different cities in Canada including
Toronto, Ottawa, Hamilton, London and Windsor. Combined, these gaseous
air pollutants were responsible for, on average, 7.7% of all premature deaths
in these eleven cities (Burnett, 1998).
A 1999 study of the population in Toronto, suggested that the gaseous air
pollutants, particularly NO2
and CO, may even have a greater impact on hospi-
tal admissions than fine particulate matter (Burnett, 1999). The researchers
have concluded that studies directed at fine particulate matter alone may
significantly underestimate the overall impact of air pollution on human
health.
U.S. Coal-Plants Have A Significant Impact On Ontario’s Air
In northeastern North American, air pollutants tend to flow from the mid-
western United States and the Ohio valley, across southern Ontario to south-
ern Quebec, and into the northeastern United States (IJC, 1998). Computer
modelling suggests that a significant percentage of the ozone and sulphates
(and therefore fine particulate matter) that affects southern Ontario originates
as NOx and SO2
in the United States (OMOE, 2001a). A significant portion of
these air pollutants is emitted from coal-fired power plants operating in the
mid-western United States.
Figure 5: Annual Average & 90th Percentile,
Respirable Particulate Matter, Ontario, 2000
0
5
10
15
20
25
30
35
Windsor
Sarnia
Kitchener
Niagara
Region
Hamilton
Mississauga
TorontoW
Oshawa
Haliburton
Ottawa
SaultSte.
Marie
NorthBay
PM2.5(ug/m3)

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Ontario Public
Health Association
Progress On Transboundary Ozone
In December 2000, Canada and the United States signed the Ozone Annex, an
agreement under the Canada-U.S. Air Quality Agreement that addresses the
precursors of ozone — NOx and VOCs. Under this agreement, the U.S. has
committed to cutting total NOx by 36% of 1990 levels by 2010 in the region of
the United States that is responsible for transboundary air pollution in Canada
(Env Can, 2001b). The U.S. expects that much of its commitment will be met
with the NOx SIP Call (State Implementation Plans), regulations introduced by
the U.S. EPA that require 22 jurisdictions to cut summertime emissions of NOx
by about 35% by 2007. Under the Ozone Annex, Ontario is committed to
cutting NOx emissions from all fossil-fuelled power plants and generators in
southern Ontario by 50% of 1998 levels to 25 kt by 2007 (Canada, 2000).
Progress Still Needed On Transboundary Pollution
Canada hopes to obtain a commitment from the United States for a reduction
in sulphur dioxide emissions of 50% or more under a Particulate Matter (PM)
Annex to be negotiated sometime in the next three years (Canada, 2001). In
order to gain significant reductions in SO2
emissions from coal-fired power
plants on the U.S. side of the border, many believe that it is essential for
Ontario to make deep cuts in SO2
emissions from coal-fired power plants in
Ontario’s electrical sector. Experience with the acid rain debate two decades
ago suggests that Canada has the greatest chance of success in negotiations
with the United States when it moves first to reduce air emissions within its
own borders. With the opening of the electrical markets to competition on
both sides of the border, this strategy may be more important than ever.
4. Coal Plants Produce Acid Rain
Acid Rain Is Still A Problem
While huge improvements have been made on the levels of acid rain by both
Canada and the United States since the 1970s, acid rain remains a serious
environmental problem today. In 1997, a multi-stakeholder task group, the
Acidifying Emissions Task Group (AETG), struck by the federal government to
assess the acid rain issue concluded that:
“Even in 2010, with full implementation of the Canada and U.S. programs,
almost 800,000 km2
in south-eastern Canada — an area the size of France
and the United Kingdom combined — will receive harmful levels of acid
rain......As a result, 95,000 lakes in south-eastern Canada will remain
damaged by acid rain” (AETG, 1997).
A significant portion
of the air pollution
that affects Ontario
is emitted from
coal-fired power
plants in the
United States.

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Beyond Coal:
and the Environment
Acid rain occurs when acids or acid aerosols that have formed in the air from
SO2
and NOx, fall to earth as rain, snow, fog or dry particulate matter. (These
are the same air pollutants that make up a significant percentage of the fine
particulate matter that is known to harm human health
when airborne.) Since 1991, when the Canada-U.S. Air
Quality Agreement was signed, Canada has reduced total
SO2
emissions by 40% of 1990 levels, and the U.S. has cut
emissions by 30% of 1990 levels. When the U.S. program
is fully implemented in 2010, SO2
emissions will be cut by
40% of 1990 levels as well (AETG, 1997). With full imple-
mentation of both programs, U.S. emissions will still be
five times greater than emissions from Canadian sources,
and will still be responsible for more than half of the acid
rain in eastern Canada (AETG, 1997).
AcId Rain Needs To Be Cut By 75%
The task group indicated that SO2
caps in Ontario, Quebec, and the mid-
western and eastern states, would have to be cut by an additional 75% if most
of eastern Canada was to be protected from acid rain. It also identified the
need to reduce emissions of NOx that are contributing to acid rain by forming
acidic nitrates in the atmosphere (AETG, 1997).
In January 2000, the Ontario government announced its intention to reduce its
acid rain cap for SO2
emissions by 50% — from 885 kt/year to 442.5 kt/year
— by 2015 (Canada, 2001). In order to achieve this 442.5 kt cap, SO2
emis-
sions from all sources in Ontario will have to be cut by 160.5 kt/year beyond
current day emissions which are 603 kt (OMOE, 2002a).
Coal-fired power plants in Ontario are responsible for about 23% of Ontario’s
SO2
emissions and 14% of the province’s NOx emissions, while fossil-fuelled
power power plants in the U.S. are responsible for approximately 70% of that
country’s SO2
emissions and 25% of its NOx emissions (CEC, 2002).
5. Coal Is A Major Source Of Mercury
Mercury Is Toxic And Persistent
Mercury is a highly toxic element that is capable of accumulating in the
aquatic food chain. While mercury is naturally present in the air, water, soil
and living organisms, releases from human activities have increased substan-
tially with industrialization and may now be responsible for one-half or more
of total emissions to the air each year (CEC, 1997). Coal-fired power plants
Acid rain still
threatens 95,000
lakes in south-
eastern Canada.

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beyond coal?
25
Ontario Public
Health Association
are one of the leading sources of mercury emissions in North America (CEC,
1997; IJC, 1998).
In high doses, mercury can kill, produce sensory and motor impairments in
adults, and produce serious developmental defects such as mental retardation
and blindness in children who are exposed prenatally (NAS, 2000; EPA, 1997).
Mercury has been clearly associated with population poisonings in Japan and
Iraq where hundreds died and thousands became seriously ill as a result of
the exposure (NAS, 2000). Mercury poisoning has resulted from high-level
occupational exposures as well.
Mercury Presents Developmental Risks To Children
In recent years, negative health impacts have been documented in
a number of populations exposed to low-levels of mercury from
environmental sources. In several studies, subtle neuro-develop-
mental effects such as deficits in attention, verbal memory, fine-
motor skills, and language development, have been seen among
children whose mothers ate fish during pregnancy (NAS,
2000)(EPA, 1997). The National Academy of Science (NAS) has
estimated that over 60,000 children per year in the United States
are born at risk from adverse neuro-developmental effects due to
prenatal exposure to mercury (NAS, 2000). The Centre for Disease
Control puts the number closer to 300,000 children per year (NAS,
2000).
Fish Consumption Restricted Because Of Mercury
In Ontario, mercury is responsible for almost one quarter of the consumption
restrictions placed on fish caught in Lake Ontario and for 99% of the con-
sumption restrictions placed on fish from inland lakes (OMNR, 1998). The
U.S. Food and Drug Administration (U.S. FDA) has issued an advisory, warn-
ing pregnant women and women of childbearing age who may become preg-
nant, to avoid eating fish species that typically have higher levels of mercury
such as shark, swordfish, king mackerel and tilefish (U.S. FDA, 2001). The
Food Advisory Panel to the U.S. FDA has recommended that the FDA extend
its advisory to include tuna. The Panel is suggesting that pregnant women eat
no more than two six-ounce servings of tuna each week (Sullivan, 2002).
Between 60,000 and
300,000 children per
year in the United
States are born at risk
from adverse neuro-
developmental effects
due to prenatal
exposure to mercury
(NAS, 2000).

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Beyond Coal:
and the Environment
Health Canada has issued an advisory, encouraging Canadians to
limit their intake of shark, swordfish and fresh and frozen tuna, to
one meal per week because of the mercury levels in these fish.
Pregnant women, women of childbearing age, and young children
are encouraged to limit their consumption of these fish to one meal
per month. Health Canada’s advisory does not apply to canned
tuna that is supposed to have lower levels of mercury because of
the age of the fish used for canning (Health Canada, 2002).
Progress Needed On Mercury
Mercury has been the subject of several international agreements in North
America. In 1994, under the Canada-Ontario Agreement Respecting the Great
Lakes Basin Ecosystem, mercury was targeted for a 90% reduction by the year
2000. While other sectors in Ontario have made significant progress towards
this goal, Ontario’s electrical sector has actually moved further away from it.
In 2000, mercury emissions from other sectors in Ontario had been reduced by
82% of 1988 levels, while mercury emissions from Ontario’s electrical sector
had increased by 18% from 500 kg/year to 590 kg/year (OCAA, 2000).
A mercury standard for coal-fired power plants is being developed under the
Canada-Wide Standards (CWS) process, and is on the agenda of the fall 2002
meeting of the Canadian Council of Ministers of the Environment (CCME)
(Env Can, 2002).
The U.S. EPA has also been involved in a standard-setting process for mercury
emissions from coal-fired power plants. The EPA has been directed by the
U.S. Congress to develop a mercury rule that is based on Maximum Achiev-
able Control Technology (MACT) (Env Can, 2002). This limit is supposed to
be proposed in 2003, finalized in 2004, and implemented in 2007 (OMOE,
2001a).
However, the standard-setting process in the United States is complicated by
the fact that a number of Bills have been proposed by various politicians with
greatly varying requirements for mercury emissions. For example, Senator
Jeffords has proposed a 4-pollutant Bill called the Clean Power Act that would
require coal plants to cut mercury emissions by 90% by 2008, while President
Bush has proposed the Clear Skies Act that, while setting a cap for mercury
emissions, would eliminate the mercury MACT Rule (Lazaroff 2002; Env Can
2002).
Mercury is
responsible for 99%
of consumption
restrictions placed
on fish from inland
lakes.

What needs
to be done?
27
Ontario Public
Health Association
III What Needs To Be Done?
1. A Three-Pronged Approach Required
A report commissioned by Environment Canada on policy options and tools
that could be employed to reduce air emissions from the electricity sector,
concludes that any strategy directed at emissions reductions from the electric-
ity sector must aim for three goals simultaneously:
1) Reduce overall demand for electricity by increasing energy efficiency;
2) Encourage generators directly, and indirectly through consumers, to
switch to cleaner fuels and emission-free technologies; and
3) Establish or maintain standards to protect public health and the envi-
ronment from specific air pollutants emitted from coal-fired power
plants in both the local and regional air sheds (Stratos, 2001).
The Commission for Environmental Cooperation (CEC), an agency established
under the North American Free Trade Agreement (NAFTA), agrees with this
assessment. In its report, Environmental Challenges and Opportunities of the
Evolving North American Electricity Market, four of the seven major recom-
mendations are directed at the promotion of energy efficiency and renewable
energies, while one is directed at the need to maintain and/or develop regula-
tory standards to protect human health and the ecosystem in all regions of
North American (CEC, 2002).
2. Energy Efficiency Has To Be Encouraged
Huge Potential In Energy Efficiency
Many believe that there is huge potential in energy conservation and energy
efficiency measures to decrease demand for electricity. Ontario’s Select Com-
mittee on Alternative Fuel Sources, a three-party committee established by the
provincial legislature, and chaired by Conservative MPP, Doug Galt, has con-
cluded that the reduction of energy demand is more important to Ontario’s
energy supply than is the creation of new supply (Select Committee, 2002).
In Ontario, electricity demand in the 1990s was reduced by 25,000 GWh
annually from the figure expected through increases in energy efficiency
(CIELAP, 2002). Energy experts, Torrie Smith Associates, have estimated that
electricity demand in Ontario could be reduced by another 35,000 GWh annu-
ally by 2012 with systematic efforts to realize those reductions (CIELAP, 2002;
“Conservation
measures and related
technologies can
also positively impact
upon employment,
technology and
manufacturing
capacity in Ontario”
(Select Committee, 2002).

What needs
to be done?
28
Beyond Coal:
and the Environment
Torrie Smith, 2002). In addition, they have estimated that another 10,000
GWh per year of electricity could be generated by industrial and commercial
co-generators2
(Torrie Smith, 2002). These estimates indicate that energy
efficiency and co-generation combined, could displace about 30% of all the
electricity generated in Ontario in 2001, which is more electricity than was
generated with coal plants in 2001 (i.e. 37,185 GWh).
Great Potential In Building And Appliance Standards
The CEC has identified changes in residential and commercial building codes
as the area with the greatest potential for energy efficiency improvements in
both Canada and the United States (CEC, 2002). In 1999, the residential
sector in Canada accounted for 17% of secondary energy use and 15.5% of
related greenhouse gas emissions while the commercial/institutional sector
accounted for 12.5% of secondary energy use and 12% of greenhouse gas
emissions (NRC, 2001a).
Energy use in the residential and commercial sectors
is greatly affected by the building standards applied
to their construction. For example, Figure 6 illus-
trates the huge variation in heating costs for homes
built under different building standards. This speaks
both, to the need to improve upon existing building
codes, and to encourage retrofits for existing buildings.
Energy use in the residential, commercial and institu-
tional sectors also reflects the energy efficiency of the
appliances used in them. In the residential sector,
space heaters, air conditioners and water heaters are
the appliances responsible for the greatest share of
energy use, while in the commercial/institutional
sectors, space heaters, air conditioners, lights, and auxiliary equipment are the
most significant appliances (NRC, 2001a).
Shared Savings Mechanism Promotes Energy Efficiency
With the changes in Ontario’s electrical market, the Ontario Energy Board
(OEB) has been given the mandate of regulating the municipal electric utilities
that have responsibility for the distribution of electricity in the province. It
has also been given the mandate to encourage electric utilities to promote
energy efficiency. In practice however, the OEB has been discouraging utilities
from promoting energy efficiency by linking their profits to their sales (OCAA,
2000).
(Data from NRC, 2001a).
Figure 6: Annual Residential Heating Costs,
Various Housing Standards
0
100
200
300
400
500
600
Typical
Existing
House
Typical New
House
Model National
Energy Code
House
R-2000 Home
Housingcostsperyear($)Energy costs
associated with
the operation of
a building over
its lifetime can
easily exceed the
initial capital cost
of the structure
(Middlesex-London
Health Unit, 2001).

What needs
to be done?
29
Ontario Public
Health Association
“But unlike
conventional energy,
renewable energy
can increase energy
security, foster rural
development, improve
human health,
and decrease our
emissions of
greenhouse gases”
(Federal Liberal Caucus
Working Group, 2002).
The OEB’s policy with respect to electric utilities is at odds with the regulatory
regime that it applies to natural gas utilities that are privately owned. For
example, Enbridge Consumers Gas has been allowed by the OEB to establish a
“shared savings mechanism” that rewards both the utility and the customers
when energy consumption is reduced through energy efficiency programs. In
1999, Enbridge’s energy efficiency programs reduced its customers’ bills by
$57.1 million while providing its shareholders with a profit bonus of approxi-
mately $4.8 million (OCAA, 2000). By ensuring that utilities profit from
energy savings, shared savings mechanisms encourage them to invest in
energy efficiency programs that are both ambitious and effective (CIELAP,
2002; CEEA, 2001).
Select Committee’s Recommendations
Ontario’s Select Committee on Alternative Fuel Sources has made twelve
recommendations on the policy changes needed to encourage energy effi-
ciency measures in Ontario. For example, it recommends that:
y The OEB require all local distribution utilities to develop energy efficiency
programs......and develop a system of incentives and penalties identical to
those applied to the natural gas sector to encourage them [i.e. shared
savings mechanisms];
y The OEB require all local distributors to establish “time-of-use” rates to
encourage conservation among their costumers;
y Ontario government review, update and expand the application of the
Ontario Energy Efficiency Act to a broader range of electrical appliances
and equipment within 12 months; and
y Ontario government revise the Ontario Building Code to incorporate the
most advanced science with respect to energy generation and energy
conservation (Select Committee, 2002).
3. Renewable Energies Have To Be Encouraged
Renewable Energies Have Huge Potential
The CEC, Ontario’s Select Committee on Alternative Fuel Sources, and the
Federal Liberal Caucus Working Group on Environmental Technologies have
all concluded that renewable energies have huge potential, from both a tech-
nological and economic perspective, to provide a significant share of clean and

What needs
to be done?
30
Beyond Coal:
and the Environment
1) Ontario’s coal-fired plants have had many years
(i.e. between 17 and 40 years) to pay off their
capital costs;
2) The renewable technologies, because they are new,
currently have low manufacturing volumes and
poor economies of scale; and
3) The conventional technologies have benefited from
long-term government subsidies that have not been
available to renewable technologies.
OntarioCleanAirAlliance
secure energy in North America (CEC, 2002a; Select Committee, 2002; Federal
Liberal Caucus, 2002).
The CEC has determined that the technology currently exists to generate
electricity from wind, geothermal, solar, hydro and biomass on both a small-
scale decentralized basis and on a large-scale centralized basis (CEC, 2002a).
Torrie Smith Associated have estimated that the new, renewable technologies,
wind, small hydro (i.e. less than 20 MW of electrical capacity), and biogas,
have the potential to produce about 19,000 GWh of electricity per year; 5,000
GWh of which could be on line by 2012 (CIELAP, 2002; Torrie Smith, 2002).
Environmental Costs Not Reflected In Price
At this time, it is estimated that it would cost 9 to 12 cents per kilowatt-hour
(kWh) to develop the wind powered capacity described above and 5 to 8 cents
per kWh to develop the small hydro electrical capacity described above. This
is considerably more than the 3.5 cents per kWh that consumers used to pay
for electricity in Ontario (CIELAP, 2002). The low cost of electricity from coal-
fired power plants in Ontario reflects several realities:
However, the cost advantage of coal-fired power plants also reflects the reality
that their environmental costs have been externalized. With coal-fired power
plants, the public health and environmental costs associated with global
climate change, smog, acid rain and mercury contamination that result from
their emissions, are not borne by the generators, nor reflected in the price
charged to customers.

What needs
to be done?
31
Ontario Public
Health Association
These costs are born collectively by all of us — in terms of poor health, in-
creased health care costs, depleted natural resources, a degraded natural
environment, and a disrupted global climate. They are also borne more heav-
ily by those whose health and livelihoods are particularly impacted by acid
rain (e.g. loggers and fishers), mercury contamination (e.g. aboriginals and
fishers), smog (e.g. the young and the elderly) and climate change (e.g. those
in poorer nations and/or tropical climates).
A study published in the journal, Science, in 2001, estimates that the real price
of coal generated electricity, when health and environmental costs are built in,
is 5.5 to 8.3 U.S. cents per kWh, which is equivalent to 8.25 to 12.5 cents per
kWh in Canadian funds (CIELAP, 2002).
Establish Policies That Support Renewables
Many believe that the introduction of the alternative technologies has been
hampered by government policies and regulations that are biased towards
existing, conventional technologies (CEC, 2002a). The Federal Liberal Caucus
Working Group on Environmental Technologies, chaired by Liberal MP, Julian
Reed, has reported that conventional energy sources have benefited from a
range of long-standing government subsidies that have not been made avail-
able to renewable or new low-impact energy sources.
In countries that have revamped their public policies to support the develop-
ment of renewable energies, the results have been impressive. For example,
Germany, which began to invest in wind power in 1990, has developed 8,000
MW of wind-generated electrical capacity, and is on track to meet its target of
22,000 MW of wind-powered electrical capacity by 2010 (CEC, 2002a).
The Federal Liberal Caucus Working Group on Environmental Technologies
has recommended that:
y Given the tremendous benefits of renewable energy, the federal govern-
ment must level the playing field and provide the same support and lead-
ership we have traditionally provided for the conventional energy sector.
Establish Renewable Energy Portfolio Standards (RPS)
A number of countries around the world have used a Renewable Energy
Portfolio Standard (RPS) as a regulatory tool to encourage the development of
renewable energy capacity. An RPS requires energy producers to supply a
certain percentage of their energy from renewable sources. In the U.S., four-
Between 1970
and 1999, direct
federal spending
on fossil fuel based
energy was $40.4
billion, while federal
support for Canada’s
nuclear industry has
exceeded $16.6
billion over the
last five decades
(Federal Liberal Caucus
Working Group, 2002).

What needs
to be done?
32
Beyond Coal:
and the Environment
2002/2003
2004/2005
2005/2005
2006 - 2019
Cumulative Increase
Table 3: Texas, Schedule for Increase in
Renewable Generating Capacity per Year
Megawatts/Year
400
850
1,400
2,000
33,300
(STRATOS, 2001)
Year
teen States have established RPS that dictate the percentage of electricity that
must be generated with renewable technologies by specified target dates.
Massachusetts has one of the most ambitious standards; it is requiring that
7% of total electricity sales come from new renewables by 2012 (STRATOS,
2001). Texas also has an aggressive program to promote
renewables. It indicates that generation capacity from renewables
must be increased by between 400 and 2000 MW each year be-
tween 2002 and 2019 (see Table 3). In the Texas rule, renewable
energy technologies include those derived from the sun, wind,
geothermal, hydroelectric, waves or tides, or biomass-based waste
products, including landfill gas (STRATOS, 2001). California has
recently signed a Bill that will require utilities to ensure that 20%
of their electricity is generated with renewable sources by 2017
(Associated Press, 2002).
Ontario’s Select Committee on Alternative Fuel Sources has
recommended that:
y Ontario establish a Renewable Portfolio Standard that is “among the most
aggressive in North America” and which includes provisions to “eliminate
carbon-based electricity generation in Ontario by 2015” (Select Committee,
2002).
Establish Tax Policies That Support Renewables
Ontario’s Select Committee on Alternative Fuel Sources has also recom-
mended that the Ontario government adopt tax policies to encourage the
development of renewable energies. For example, in December 2001, the
Federal government announced that it will be establishing a Wind Power
Production Incentive of up to 1.2 cents per kWh to support the installation of
1,000 MW of new wind energy in Canada over a five-year period. Ontario’s
Select Committee has recommended, among other things, that the Ontario
Government:
y Match the Federal Wind Power Production Incentive and consider expand-
ing this program to include renewable technologies such as solar, biomass
and small hydraulic projects within Ontario;
y Grant tax holidays to wind farms similar to the 10-year tax holiday offered
for new, rebuilt or expanded hydro-electric stations (Select Committee,
2002); and
OntarioPowerGeneration

What needs
to be done?
33
Ontario Public
Health Association
y Instruct the Ontario Energy Board to establish a Systems Benefit Charge of
0.1 cents per kilowatt-hour (kWh) on electricity bills to fund a renewable
energy trust fund to support the development of renewable energy pro-
grams (Select Committee, 2002).
4. Coal-Fired Power Plants Should Be Phased Out
No Emission Controls For CO2
Ontario’s Select Committee on Alternative Fuel Sources has recommended the
phase-out of all coal- and oil-fired power plants in Ontario by 2015 and the
closure of the Atikokan and Thunder Bay Generating Stations by 2005. It has
also recommended that the Ontario Government establish stringent emissions
limits for the operation of all current coal- and oil-fired power plants that are
equal to, or less than, the emissions limits for natural gas fired generators
(Select Committee, 2002).
A large number of organizations have called for the phase-out of Ontario’s
coal-fired power plants because: a) they are huge contributors of greenhouse
gases; and b) there is currently no commercially available technology that can
be used to reduce their CO2
emissions. There are a few emission control
technologies that can be used to remove a significant portion of the other air
pollutants (i.e. SO2
, NOx and mercury) from the stacks of coal-fired power
plants, but none of these technologies reduce CO2
emissions. In fact, some of
these technologies actually increase CO2
emissions because they require en-
ergy to operate (OMOE, 2001a).
As can be seen in Table 4 below, even when highly efficient emission control
devices are installed on coal-fired power plants, their emissions are still much
greater than those that can be achieved with other available options. This is
particularly true for CO2
emissions.
Table 4: Emission Reductions Comparison Between Coal-Plants
with Emission Control Devices and Other Options
(I) Selective Catalytic Reduction (SCR) & Low-NOx Burners
(II) Flue Gas De-Sulphurization (FGD) with high-sulphur coal
(III) Expected capability of technologies under development
(* data from OMOE, 2001a; ** data from TPH, 2000)
Pollutant Energy
Efficiency
Measures
(% Red’n)
Wind
Turbines
(% Red’n)
Combined
Cycle Natural
Gas Turbines
(% Red’n)**
OPG Plants
& Emission
Controls
(% Red’n)*
Existing
OPG Coal
Plants
(kg/MWh)*
Nitrogen Oxide
Sulphur Dioxide
Mercury
1.2
4.6
63-80 (l)
84 (ll)
70 (lll)
90
99+
99+
100
100
100
100
100
100
Carbon Dioxide 890 Slight increase
with I&II
60 100 100
0.017
(g/MWh)
There is no
commercially
available technology
that can be used
to capture CO2
emissions from
coal plants.

What needs
to be done?
34
Beyond Coal:
and the Environment
Multiple Benefits From Phasing Out Coal
While CO2
may be the air pollutant that drives the phase out of coal-fired
power plants, there will be many other public health and environmental
benefits besides those associated with climate change. If coal based electrical
capacity were displaced with renewable technologies and energy efficiency
measures, total emissions of SO2,
NOx, and mercury in this province could be
cut by up to 23%, 14% and 23% respectively, while CO2
emissions could be
cut by up to 20%. If coal based electrical capacity were displaced with a low
emissions alternative such as high efficiency natural gas generators, total
emissions of SO2,
NOx, and mercury in the province could be reduced by up to
23%, 12% and 23% respectively, while total CO2
emissions could be reduced
by up to 12%.
Minor Increases In Cost To Phase-Out Coal
An economic analysis conducted for the Ontario Clean Air Alliance (OCAA), a
non-governmental organization, indicates that, if a significant portion (i.e.
83%) of Ontario’s coal-generating capacity were converted to high efficiency
natural gas generation by 2014, electricity prices for the typical residential
customer would increase by only $1.86 per month (OCAA, 1998). An eco-
nomic analysis conducted for Ontario Power Generation (OPG) suggests that it
should be possible to offer electricity from new, high efficiency natural gas
turbines in 2012 without raising electricity prices above the rate expected for
that year (OCAA, 2001). These economic analyses indicate that coal-fired
power plants could be phased out of use in this province within a fairly tight
time frame with a relatively small increase in the cost of electricity for con-
sumers with some use of cost competitive low emission technologies such as
high efficiency natural gas generation.3
Transitional Technologies
While high efficiency natural gas generators represent a huge improvement
over coal-fired power plants, the fact that they do emit large quantities of CO2,
combined with the fact that natural gas is a non-renewable resource, suggests
that these generators should be viewed as a transitional technology that must
eventually be replaced with renewable technologies.

What needs
to be done?
35
Ontario Public
Health Association
In the State of Oregon, they have established a mandatory CO2
standard that
encourages the development of energy efficiency, co-generation and renewable
energies while allowing the establishment of new gas-fired power plants.
Under this standard, all new power plants must achieve a net emission rate
for CO2
that is 17% below the rate achieved by the most efficient gas-fired
plants currently operating in the United States (Oregon, 2002). This standard
can be achieved by:
y Increasing the efficiency of the proposed plant;
y Implementing co-generation so that waste heat is used for some productive
purpose;
y Implementing projects off-site such as renewable energy or energy effi-
ciency projects that “offset” excess CO2
emissions; or
y Contributing funds to The Climate Trust that will in turn buy CO2
“offsets”
elsewhere.
The rules define “offsets” as any action that will avoid, sequester, or displace
CO2
emissions (Oregon, 2002).
This approach could be adopted in Ontario to allow the development of cost
competitive low emissions alternatives as transitional technologies while
actively encouraging the development of energy efficiency measures and
renewable energies that would ultimately replace them.
Nuclear Energy Is A Transitional Technology
While nuclear energy is recognized by some as an alternative to coal because
it does not present the air pollution and climate change concerns that coal
does, neither the Select Committee on Alternative Fuel Sources, nor the CEC
have recommended it as an alternative to coal-fired power plants. This can be
attributed to a number of factors.
First of all, while nuclear energy does not contribute to smog or climate
change, it does present other health, safety and security issues for workers,
the public and the environment (CEC, 2002a). These concerns are particularly
acute at the front end of the process, during the mining and processing of
uranium oxide, and at the back end of the process, during the transportation
and storage of highly hazardous radioactive wastes that can take thousands of
years to decay (McKay, 1983).

What needs
to be done?
36
Beyond Coal:
and the Environment
Secondly, nuclear energy is expensive. Ontario Hydro accumulated $38 billion
in debt in the 1980s and 1990s, when much of its activity was directed at the
building and repairing of nuclear generating stations. This debt, and the high
electricity prices that accompanied it, are the main reasons that the Ontario
Government decided to introduce competition to Ontario’s electrical sector
(OMOE, 2002). In fact, in order to ensure that Ontario Hydro’s successor
company, Ontario Power Generation, would be viable, the Ontario government
“stranded” approximately $22 billion of Ontario Hydro’s debt. This stranded
debt will have to be paid off by Ontario consumers as a surcharge paid on all
electricity that enters the distribution system for years to come (OMOF, 1998).
While the OPHA recognizes that nuclear energy will serve an important role
as a transitional technology in Ontario during the years in which renewable
energy capacity and energy efficiency are being developed, it does not believe
that nuclear energy should divert resources or regulatory support away from
that needed to develop renewable energy capacity and energy efficiency stand-
ards in Ontario in the coming years.

37
How do we
get there?
Ontario Public
Health Association
IV How Do We Get There?
1. Action Needed From The Federal Government
The Federal government has responsibility for air pollution that crosses pro-
vincial or international borders. As such, it has responsibility for some aspect
of all four environmental problems presented by coal-fired power plants.
Ontario’s coal-fired power plants contribute to acid rain in Quebec and smog
from Ontario to Maine. They contribute to global climate change that is affect-
ing the entire planet and mercury that contaminates food supplies from the
Great Lakes to Canada’s far north.
The Federal government must keep bi-national and multi-national commit-
ments on acid rain, mercury and smog. It has also been actively involved in
the multi-national negotiations related to climate change with the Kyoto Proto-
col. In addition, it will have responsibility for negotiating a PM Annex with
the United States in the next few years to address U.S. sources of SO2
that
threaten the health of Ontario residents and the environment of all of eastern
Canada.
By encouraging a phase-out of coal-fired power plants in Canada, the federal
government could make progress on a number of environmental issues simul-
taneously. It would be making significant progress on climate change, mer-
cury pollution, smog and acid rain directly, while setting the stage for the next
round of negotiations with the United States on SO2
. If the federal government
can also tie these emission reductions to investments in renewable energies,
energy efficiency programs and co-generation, it would also be encouraging
the energy shift required to address climate change in the long-term.
Newly Revised Guidelines For Coal-Fired Power Plants
In November 2001, the federal government released revisions to the National
Guidelines on Thermal Power Generation Stations for consultation. Unfortu-
nately the proposal is lacking in a number of significant ways. First of all, the
revisions are directed at new fossil-fuelled power plants; they are not directed
at existing plants. Consequently, they will have little impact on the near-term
situation in Ontario because there are no current proposals for new plants or
for major modifications to existing plants. Secondly, the proposal involves
revisions to National Guidelines that have no force in law. Neither the electri-
cal utilities, nor the provinces have to abide by the provisions contained in
By phasing out coal
plants, the federal
government could
make progress on
climate change,
smog, acid rain,
and mercury while
setting the stage
for the next round
of negotiations with
the United States.

38
How do we
get there?
Beyond Coal:
and the Environment
these Guidelines. Thirdly, the reductions proposed for SO2
(at least a 70%
reduction) and NOx (60% reduction), while significant, will do little to dis-
courage the on-going use of coal. Finally, no emission performance rates have
been proposed for mercury or for CO2
.
Recommendations To The Federal Government
It is recommended that the Federal government:
3 Ratify and implement the Kyoto Protocol as currently written, recogniz-
ing that it is only the first step towards the 60 to 80% reduction in
greenhouse gases that will be required to retard global climate change;
3 Provide municipalities with stable, long-term funding, that is not de-
pendent upon participation by the province, with which to promote
energy efficiency projects within their communities;
3 Establish a schedule of ambitious and increasing renewable energy
targets to guide the development of energy policies, environmental
regulations, and budgetary commitments at the federal level for the
coming years;
3 Provide financial support to renewable technologies that it equal to
that traditionally provided to conventional energy sources; and
3 Establish regulations under the Canadian Environmental Protection Act
(CEPA) that encourage the phase out of coal-fired power plants in
Canada by 2010.
2. Action Needed From The Province
The province, as the jurisdiction with primary responsibility for public health,
education, environment and natural resources, clearly has an interest in the
public health and environmental impacts presented by coal-fired power plants.
The Ontario government is also very aware of the continued contribution of
U.S. sources to air pollution and acid rain in this province. By moving to
phase out coal-fired power plants in Ontario, the Ontario government strength-
ens it position on the electrical sector for the next round of Canada-U.S. nego-
tiations on transboundary air pollution.
The province has
a multitude of
avenues by which
it can encourage a
shift away from
coal towards
energy efficiency
and renewables.

39
How do we
get there?
Ontario Public
Health Association
The province is also the jurisdiction with primary responsibility for energy
issues within its jurisdiction, building standards, planning acts and municipal
legislation. This means that the province has a multitude of opportunities and
avenues by which it can encourage a shift away from coal-fired power plants
towards energy efficiency, renewable energies, and other practices that protect
human health and the environment.
Ontario’s Select Committee and the CEC have both concluded that, in addition
to environmental benefits, investments in renewable energies and energy
efficiency present many economic benefits for society.
Emissions Trading As A Regulatory Framework
The Ontario government has introduced an emissions trading scheme as the
framework within which to reduce air emissions from Ontario’s electrical
sector, and eventually from all industrial sectors in Ontario. When properly
designed, emissions trading schemes can effectively reduce emissions to an air
shed, while giving the regulated organizations some flexibility in their re-
sponse. In the United States, where emissions trading was used to reduce SO2
emissions under the acid rain program, emissions trading was found to be a
cost-effective regulatory tool.
Because emissions trading schemes provide the regulated organizations with
greater flexibility, there is often less resistance to them than to the more tradi-
tional regulatory approaches. If, however, an emissions trading scheme is not
properly designed, it can fail to produce the emission reductions desired, or
even worse, increase air pollution on a region-wide basis.
Emissions trading schemes also have the potential to create environmental
justice inequities; areas that already have air pollution problems can become
burdened with more. These “air pollution havens” are more likely to occur in
areas that are socio-economically disadvantaged.
Cap And Trade Versus Emissions Reduction Trading
There are two basic forms of emissions trading:
y A closed-market trading system called “cap-and-trade”; and
y An open-market trading system called “emission reduction trading”.
With a cap-and-trade system, the regulator establishes a cap on the total
volume of an air pollutant that can be emitted by all the regulated sources in a
common air shed, and divides that cap into emission allowances that can
If an emissions
trading scheme is
not properly designed,
it can fail to produce
the emission
reductions desired,
or worse, increase
air pollution on a
region-wide basis.

40
How do we
get there?
Beyond Coal:
and the Environment
either be auctioned to the emitters or assigned to the regulated sources on the
basis of historic or permitted emissions. Companies must keep their air emis-
sions within the volume allowed them, or purchase allowances from other
companies. The emissions trading system used successfully by the U.S. gov-
ernment to reduce acid rain was a cap-and-trade scheme (STRATOS & GCSI,
2001).
Emission reduction trading programs establish a reference level of emissions
for each air pollutant for every source in a common air shed. The reference
level may be the volume of emissions for a selected year. When one of the
sources in that air shed reduces its emissions below that reference level, it
creates emission reduction credits that can be “banked” for future years or
sold to other sources in the air shed. The effectiveness of this system depends
upon the reference levels established and the reliability of the emission esti-
mates (STRATOS & GCSI, 2001).
Flaws In Ontario’s Emissions Trading Scheme
The emissions trading program introduced by the Ontario Government com-
bines features of the closed and open market trading systems. It caps On-
tario’s electrical sector for SO2
and NOx while allowing the electrical sector to
buy emission reduction credits from uncapped sources, when the uncapped
sources emit less pollution than they are allowed to emit, based on other
regulations that currently exist or that are subsequently introduced (STRATOS
& GCSI, 2001).
A number of organizations have expressed serious concerns with Ontario’s
scheme including Environment Canada and the U.S. Environmental Protection
Agency. Of particular concern to many is the fact that Ontario is allowing the
electrical sector, to which emission caps apply, to buy emission reduction
credits from sectors for which there are no emission caps. Organizations are
concerned that this practice could make the program ineffective, or worse,
lead to an increase in emissions to the overall air shed (U.S. EPA, 2001; Env
Canada, 2001).
Caps For NOx Too Modest
In addition to a properly designed emissions trading scheme, aggressive and
declining air emission caps are needed to drive the desired outcome. The caps
established by the provincial government are far from aggressive. In fact, they
appear to encourage a continued reliance on coal-fired power plants.
Environment Canada
and the U.S. EPA
have both expressed
serious concerns with
Ontario’s emissions
trading scheme.

41
How do we
get there?
Ontario Public
Health Association
The NOx cap established for the electrical sector is far too modest.
The Ontario government has established a cap of 28 kilotonnes
(kt) for NOx from all electrical generators by the year 2007. How-
ever, the Ontario Government will also allow each organization to
exceed its cap by 33% provided that it has purchased emission
reduction credits from other organizations. When the allowances
are added to the caps, it becomes apparent that emissions from
this sector can remain as high as 37.24 kt until 2010 (see Figure
7).
While a 33% reduction in emissions sounds substantial, it must
be put in perspective. When fully implemented, Ontario’s regula-
tory program will allow higher emissions of NOx from Ontario’s
electrical sector in 2010 than actual emissions from Ontario Hy-
dro’s five coal-fired power plants in 1996 (35.4 kt). Given the
health concerns associated with ozone levels in the province,
these caps are far from satisfactory.
Caps Do Not Ensure Ozone Annex Commitment
With the NOx cap established, it is not clear how the government will meet its
commitment under the Ozone Annex to cut NOx emissions from all fossil-
fuelled generators in central and southern Ontario to 25 kilotonnes by 2007
(Government, 2000). Table 5 illustrates how the provincial government envi-
sions NOx emissions being allocated over time under its Emissions Trading
Regulation. With the 33% allowance added to the caps for each region of
Ontario, it appears that NOx emissions from generators in southern and cen-
tral Ontario could exceed the 25 kt cap set under the Ozone Annex by nearly 8 kt.
Notes:
OPG is Ontario Power Generation
IPP represents Independent Power Producers
(Data drawn from OMOE, 2001a; TPH, 1999;
OMOEE, 2001a)
Figure 7: Nitrogen Oxide Emissions
from Ontario's Electrical Sector,
Past, Present & Projected
Table 5: NOx Emissions Allocation Timetable Under
Ontario’s Emissions Trading Regulation
(Data derived from OMOEE, 2001c)
*OPG generators
Overall
Cap (kt)
OPG’s
Cap (kt)
OPG Cap
& 33%
Allowance (kt)
Cap for Other
Generators
(kt)
Cap for Others
& 33%
Allowance (kt)
2002-3
2004
2005
2006
36
36
36
36
Overall
Cap (kt)
35
25
22.4
21.1
Cap for S.
& Central
Ontario
(kt)***
46.6
33.3
29.8
28.1
Cap & 33%
Allowance for
S. & Central
Ontario (kt)***
no cap
10
12.6
13.9
Cap for Rest
of Ontario (kt)
13.3
16.8
18.5
2007
2008-10
28
28
*15.5 /**9.1
24.6
*1.5/**0.9
2.4
3.2
3.2
32.7
32.7
Cap & 33%
Allowance
for Rest of
Ontario (kt)
**Other generators
*** Identifies generators affected by Ozone Annex.
0
10
20
30
40
50
60
70
1996 1999 2003 2007 2010
kilotonnes
OPG OPG & IPP OPG & IPP & Credits

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